Registrar’s Office Audit
Kaplan University
Chicago, IL
May 5-6, 2009
Reid Kisling, Senior Consultant
Role of the Registrar: Philosophy
Observations


The mission statement for a Registrar’s Office drives
all decision making and relationships with other
offices. The Registrar’s Office at Kaplan University,
while discussions of mission have occurred in the
past, does not have an explicit mission statement.
The office should be commended for a good working
relationship with the academic enterprise at the
institution (this is not a common occurrence at other
higher education institutions).
Registrar’s Office Audit
Kaplan University
May 5-6, 2009
‹#›
Role of the Registrar: Organization
Observations


Office staff should be empowered at the lowest level
possible in the organizational structure to make
decisions that affect their work. This includes the
ability to make exceptions to policy when interacting
with faculty, staff, or students and should be in the
student’s best interest in line with office and
institutional mission.
The level at which some decisions can and should be
made is unclear amongst staff.
Registrar’s Office Audit
Kaplan University
May 5-6, 2009
‹#›
Role of the Registrar
Recommendations


The mission statement for the office should be
clarified and communicated explicitly to all staff.
Decisions should be tied to office mission as the
mission of the office is tied back to that of the
institution.
The office should clarify who has authority for making
specific decisions and empower staff to make those
decisions in the best interest of students.
Registrar’s Office Audit
Kaplan University
May 5-6, 2009
‹#›
Communication: General
Observations


Different departments throughout the institution office
training to their staff (i.e., orientation) regarding data
entry and policy for student records. However, in
most cases, this training has not been reviewed fy
the Registrar’s Office to insure compliance with
institutional policy and procedure.
The office does not have a defined process for
proactive communication to students, faculty, and
staff (i.e., deadlines).
Registrar’s Office Audit
Kaplan University
May 5-6, 2009
‹#›
Communication: General
Observations, continued


The office does not have recent student satisfaction
data that can be used to assess effectiveness of
efforts from the perspective of students themselves
(however, plentiful operational data exist for
assessment).
The institution does not clearly communicate the
need for submission of official transcripts submitted
prior to admission for its Master’s and advanced start
students.
Registrar’s Office Audit
Kaplan University
May 5-6, 2009
‹#›
Communication: Catalog
Observations

Course frequency (e.g., every fall, every semester) is
not communicated clearly in the catalog or other
advising document from which students can make
appropriate advising decisions.
Registrar’s Office Audit
Kaplan University
May 5-6, 2009
‹#›
Communication
Recommendations


Student record training offered by different
departments throughout the institution should be
vetted by Registrar’s Office staff to insure compliance
with policies and procedures.
The department should consider a triggered
communication calendar (can be as sophisticated as
a defined CRM system) that communicates key
messages to faculty, staff, and students on a
predefined calendar (date or process driven).
Registrar’s Office Audit
Kaplan University
May 5-6, 2009
‹#›
Communication
Recommendations, continued



The office does consider delivering student
satisfaction survey(s) to assess effectiveness of
efforts directly from students.
The institution must clearly communicate the need for
submission of official transcripts for admission.
The institution should consider where best to
communicate course frequency information (catalog
or other document).
Registrar’s Office Audit
Kaplan University
May 5-6, 2009
‹#›
Student Records: Transcript
Processes and Procedures
Observations


The transcript legend is unique to each Kaplan
University college based on institutional history and
some policies peculiar to each location.
Credits awarded for prior learning are not necessarily
clearly defined on student transcripts but are instead
coded as the course for which credit was awarded at
the university. Credit is only awarded for equivalency
to existing catalog courses (in both content and credit
hours).
Registrar’s Office Audit
Kaplan University
May 5-6, 2009
‹#›
Student Records: Transcript
Processes and Procedures
Observations, continued



The university does not have a defined policy
regarding what dismissal status—disciplinary vs.
academic—should and can appear on the
institutional transcript.
Grade changes submitted subsequent to degree
conferral (sometimes a year later) can retroactively
change a student’s GPA post-conferral.
Institutional plans to implement an honors track for
health sciences has implications for transcripts.
Registrar’s Office Audit
Kaplan University
May 5-6, 2009
‹#›
Student Records: Records
Management and Retention
Observations


The office does not have a specific record retention
policy that identifies all types of documents that
should be maintained in the student file and the
retention schedule for each (including the time at
which they should be purged, if ever).
The university does not have a policy regarding what
documents are necessary to process a student’s
name change request.
Registrar’s Office Audit
Kaplan University
May 5-6, 2009
‹#›
Student Records: Records
Management and Retention
Observations


Documentation of student records (specifically,
advising comments) in Artemis differs by staff
member or department, leading to disparities in the
kind of information included in the system. Some of
this information may not be intended by the person
entering the data as viewable to the student (which is
governed by FERPA).
Exceptions granted for student curricular changes
may not be documented consistently in all cases.
Registrar’s Office Audit
Kaplan University
May 5-6, 2009
‹#›
Student Records
Recommendations


The university should standardize, to the extent
possible, the information included on the transcript
legend for each Kaplan institution.
The university should consider labeling prior learning
credit based on work as presented (not awarded).
Though it is an institutional decision, credit may be
awarded credit hours that may not exactly meet
minimum credits of specific university courses (which
may allow awarding credit for elective hours).
Registrar’s Office Audit
Kaplan University
May 5-6, 2009
‹#›
Student Records
Recommendations, continued


The university should consider and define policy
regarding what student status (i.e., probation, good
standing, dismissal) appears on the institutional
transcript.
The institution should consider a length of time during
which to consider grade changes for students who
graduate which may result in “freezing” a student’s
GPA upon graduation.
Registrar’s Office Audit
Kaplan University
May 5-6, 2009
‹#›
Student Records
Recommendations, continued

The institution must consider the manner in which the
honors track for health sciences will appear on
student transcripts. Possibilities range from no
notation to specific honors courses (noting the
honors designation in the course title) to a notation of
a student’s involvement in the program (on a termby-term basis). Consideration should be given to
students who may leave the program mid-stream and
how the information will be displayed on their
transcripts appropriately.
Registrar’s Office Audit
Kaplan University
May 5-6, 2009
‹#›
Student Records
Recommendations, continued

The office should create an explicit record retention
policy in which all types of documents are identified
for the office and the student file and listing how long
they are to be maintained (or key times when they
are purged). Special attention should be paid to the
following types of existing records:
– Admissions reference forms
– Advising communications
Registrar’s Office Audit
Kaplan University
May 5-6, 2009
‹#›
Student Records
Recommendations, continued


The university should define what documents are
necessary (e.g., Social Security card) to process a
student’s name change request.
Training should be provided to staff entering advising
comments in Artemis to promote consistent
information included in the system. Curricular
exceptions should also documented consistently in
all cases. Staff should understand that such
comments are viewable to students upon request.
Registrar’s Office Audit
Kaplan University
May 5-6, 2009
‹#›
Advising/Degree
Audit/Graduation/Commencement:
Observations
Transfer
Evaluation

The institution currently does not allow students to
submit transfer coursework or prior learning
evaluations once in the program. However, students
may be able to earn such credit while also enrolled in
a program at Kaplan.
Registrar’s Office Audit
Kaplan University
May 5-6, 2009
‹#›
Advising/Degree
Audit/Graduation/Commencement:
Observations
Graduation



Currently, the Registrar approves graduates versus
formal approval by the faculty or board of trustees.
Current policy requires that students must complete
25% of coursework at the university to be considered
for graduation honors.
The university has precedent for awarding
posthumous degrees. However, no policy exists
describing when such a degree may be awarded
(e.g., number of hours or percentage of program).
Registrar’s Office Audit
Kaplan University
May 5-6, 2009
‹#›
Advising/Degree
Audit/Graduation/Commencement:
Observations
Diplomas


Diplomas are official documents signifying the
completion of the student’s program. The university
does not have an explicit policy regarding the name
students may select to place on their diploma.
The office does not have a stated policy regarding
reprinting of diplomas and under what circumstances
may a reprint be provided (are second copies of the
document permissible?).
Registrar’s Office Audit
Kaplan University
May 5-6, 2009
‹#›
Advising/Degree
Audit/Graduation/Commencement:
Observations, continued
Diplomas


The institutional database does not currently have
the ability to differentiate names for each student
(though it does allow for recording of a
“nickname”). One primary data field typically included
in many database systems is the “attended as” name
or the the student’s preferred name for the diploma.
Diploma reprints often contain current signatures and
dates which can lead to the appearance that the
degree was conferred recently.
Registrar’s Office Audit
Kaplan University
May 5-6, 2009
‹#›
Advising/Degree
Audit/Graduation/Commencement:
Observations, continued
Diplomas

International students often have need to provide a
notarized diploma as documentation of the
completion of a degree program (other cultures do
not consider a transcript as sufficient documentation
as they would a diploma).
Registrar’s Office Audit
Kaplan University
May 5-6, 2009
‹#›
Advising/Degree
Audit/Graduation/Commencement
Recommendations


The institution should consider if the current policy of
restricting transfer and prior learning evaluations
once in the program is in the best interest of students
and best matches their needs. If changed, the policy
of final deadline for submission must be
communicated clearly to students and advisors.
The institution should review its charter (or state law)
and determine who must approve graduates prior to
degree conferral (registrar, faculty, or trustees).
Registrar’s Office Audit
Kaplan University
May 5-6, 2009
‹#›
Advising/Degree
Audit/Graduation/Commencement
Recommendations, continued


The institution should review its current policy that
requires that students must complete 25% of
coursework at the university to be considered for
graduation honors to determine if students have
completed enough resident hours to be considered.
The university must develop policy describing when a
posthumous degree may be awarded. The institution
should consider awarding an honorary degree in
such instances (which grants more flexibility).
Registrar’s Office Audit
Kaplan University
May 5-6, 2009
‹#›
Advising/Degree
Audit/Graduation/Commencement
Recommendations, continued



The university should develop policy regarding the
name students may select to place on their diploma
(e.g., must be a form of student’s legal name).
The office develop policy clarifying under what
circumstances the reprint of a diploma is permissible
(including if the original should be returned if
possible).
The institution should consider the addition of a
diploma name database field to track this data.
Registrar’s Office Audit
Kaplan University
May 5-6, 2009
‹#›
Advising/Degree
Audit/Graduation/Commencement
Recommendations, continued


Diploma reprints, if containing current signatures and
dates, should include a statement on the diploma
indicating the original information has changed.
The institution should consider providing a second
notarized diploma (may also need an apostille) to
some international students who may need the
notarized copy for documentation. This may require
the institution to define the students to whom this will
be provided (i.e., all international students?).
Registrar’s Office Audit
Kaplan University
May 5-6, 2009
‹#›
Information Technology and Support
Equipment: General
Observations


The university currently operates two student records
database systems which contain redundant data. The
CVue system (now considered by the institution as
the primary data source) was implemented to replace
the aging KCC system. Both systems have been
“mirrored” for several years. The continued use of
both systems requires dual entry by staff and
requires significant human resources to maintain.
Some staff still consider KCC to have primary data.
Registrar’s Office Audit
Kaplan University
May 5-6, 2009
‹#›
Information Technology and Support
Equipment: General
Observations, continued



Due to staff data entry preferences in one system
over the other, student record data discrepancies
may be introduced.
Due to changes in IPEDS racial classification,
cleanup of system data will be necessary for a future
IPEDS reporting period.
Security to student database records appears to be
open to all staff who have access to each database
module rather than based on a defined “role.”
Registrar’s Office Audit
Kaplan University
May 5-6, 2009
‹#›
Information Technology and Support
Equipment: General
Recommendations



The university community must recognize the CVue
as the primary database which will require significant
coordination and communication. Staff must be
trained on data entry in the CVue system, specifically
for academic advising information.
Discrepancies betweeen KCC and CVue must be
identified and resolved.
The university must determine a reasonable
“mothball” process for KCC to recapture staff time.
Registrar’s Office Audit
Kaplan University
May 5-6, 2009
‹#›
Information Technology and Support
Equipment: General
Recommendations, continued


The office should consider how to address the
IPEDS racial classification changes (including
needed modifications to current system data
structure) and plan for migration for a future IPEDS
reporting period.
Security to student database records must be defined
based on one’s “role.” Definition of each “role” should
include which records and what level of access is
appropriate (e.g., view vs. update access).
Registrar’s Office Audit
Kaplan University
May 5-6, 2009
‹#›
Legal: FERPA
Observations



The institution does not currently define “directory
information” nor how it may be released.
The institution does not currently define the point at
which an applicant becomes a “student” at which
time the student record is created (according to
FERPA). This may differ by institution but must be no
later than the date of beginning coursework.
The institution does not currently define the process
by which a student may view their student record(s).
Registrar’s Office Audit
Kaplan University
May 5-6, 2009
‹#›
Legal: FERPA
Observations, continued


FERPA training for faculty and staff is inconsistent
with the exception of staff in the Registrar’s Office.
The Registrar’s Office currently restricts release of
information unless signature release is submitted.
However, the institution is considering submission of
enrollment data to the National Student
Clearinghouse at which time definitions of directory
information and release of information guidelines
must be explicit.
Registrar’s Office Audit
Kaplan University
May 5-6, 2009
‹#›
Legal: FERPA
Observations, continued


The office does not have a clearly defined process
for release of student records upon receipt of
subpoena.
The institution provides annual notification of FERPA
rights to students in the institutional catalog.
Registrar’s Office Audit
Kaplan University
May 5-6, 2009
‹#›
Legal: FERPA
Recommendations



The institution must appropriately define “directory
information” including the provisions under which
such information may be released.
The institution may choose to allow students to
restrict all or part of their records for release but must
define to faculty and staff how such a restriction is
identified in the student record database.
The institution must define the point at which the
student record is created.
Registrar’s Office Audit
Kaplan University
May 5-6, 2009
‹#›
Legal: FERPA
Recommendations, continued


The institution must define the process by which a
student may view his/her record and provide annual
notification to students as required by the FERPA
regulations. Annual notification included in the
catalog should be reviewed to determine if it is the
appropriate notification process for students.
The institution should consider policy for restriction of
student record release and what is allowable (all or
part of the record).
Registrar’s Office Audit
Kaplan University
May 5-6, 2009
‹#›
Legal: FERPA
Recommendations, continued



The institution should define the process for
submission of records following receipt of a subpoena.
As the institution moves forward with enrollment
information submissions to the Clearinghouse, the
office must consider FERPA restrictions in the CVue
system and restricting data on reports.
The office should review the FERPA training (and
confidentiality agreements) provided to faculty and
staff at the institution to insure appropriateness.
Registrar’s Office Audit
Kaplan University
May 5-6, 2009
‹#›
Thank you!
Reid Kisling
rkisling@gmail.com
consulting.aacrao.org
Registrar’s Office Audit
Kaplan University
May 5-6, 2009
‹#›